Privacy
Policy

1. Introduction

Palak Diam Inc. ("Palak Diam," "we," "us," or "our") is a diamond buying and selling company headquartered in Los Angeles, California. We are committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website at palakdiam.com (the "Site"), contact us, or engage in a transaction with us. Please read this Privacy Policy carefully. By using our Site or services, you agree to the practices described in this policy.

2. Information We Collect

We collect personal information that you voluntarily provide to us, including when you submit an inquiry or contact form, request a diamond valuation or quote, enter into a purchase or sale transaction, apply for a trade credit account, complete our Anti-Money Laundering (AML) compliance form, or communicate with us by phone, email, or in person. The types of information we may collect include: full name, business name, mailing address, email address, telephone number, diamond and jewelry descriptions, transaction details, government-issued identification (as required by law), and financial account information for payment purposes.

When you visit our Site, we may also automatically collect technical information including IP address, browser type and version, operating system, referring URL, pages viewed, and time spent on pages. This information is collected through cookies, web beacons, and similar tracking technologies.

3. How We Use Your Information

We use the information we collect for the following purposes: (a) Transaction Processing — to evaluate, quote, purchase, or sell diamonds and jewelry; to process payments; and to fulfill contractual obligations; (b) Compliance — to comply with applicable federal and state laws, including the Bank Secrecy Act, anti-money laundering regulations, the Kimberley Process Certification Scheme, and California consumer protection laws; (c) Communication — to respond to your inquiries, send transaction confirmations, and provide customer service; (d) Marketing — to send promotional materials, trade show announcements, and industry updates, where you have consented or where permitted by law; (e) Site Improvement — to analyze usage patterns and enhance user experience; (f) Security — to detect, investigate, and prevent fraudulent transactions and other illegal activities.

4. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your information with: (a) Service Providers — trusted vendors who assist us in operating our business (e.g., FedEx, insurance providers, payment processors, IT service providers), subject to confidentiality agreements; (b) Industry Partners — gemological laboratories (e.g., GIA), industry associations (e.g., RJO, IDCA, JBT), or trading platforms (e.g., RapNet) as necessary to complete transactions; (c) Legal Requirements — when required by law, regulation, or legal process, including disclosures to law enforcement or regulatory agencies; (d) Business Transfers — in connection with a merger, acquisition, or sale of assets; (e) With Your Consent — in any other circumstances where you have provided explicit consent.

5. California Privacy Rights (CCPA / CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA): Right to Know — you may request information about the categories and specific pieces of personal information we have collected, the sources, purposes, and categories of third parties with whom it is shared. Right to Delete — you may request deletion of personal information we have collected, subject to certain exceptions. Right to Correct — you may request correction of inaccurate personal information. Right to Opt-Out — we do not sell or share personal information for cross-context behavioral advertising. Right to Non-Discrimination — we will not discriminate against you for exercising your privacy rights. To exercise any of these rights, please contact us at [email protected] with "California Privacy Request" in the subject line. We will respond within 45 days as required by law.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, to comply with our legal obligations (including anti-money laundering record-keeping requirements, which may require retention for five years or more), resolve disputes, and enforce our agreements.

7. Data Security

We implement commercially reasonable technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include secure data transmission (SSL/TLS encryption), access controls, and secure storage practices. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

8. Cookies and Tracking Technologies

Our Site may use cookies and similar technologies to enhance your browsing experience. You can control cookie settings through your browser preferences. Please note that disabling certain cookies may affect the functionality of our Site. We do not currently respond to "Do Not Track" signals from browsers.

9. Children's Privacy

Our Site and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a minor, please contact us immediately so we can delete it.

10. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. We will post the revised policy on this page with an updated "Last Updated" date. Your continued use of the Site after any changes constitutes your acceptance of the revised policy. We encourage you to review this policy periodically.

11. Sensitive Personal Information

Under the California Privacy Rights Act (CPRA), certain categories of personal information are classified as "Sensitive Personal Information" (SPI) and are subject to additional protections. In the course of our Anti-Money Laundering (AML) compliance program and transaction processing, we may collect the following categories of SPI: government-issued identification numbers (e.g., driver's license, passport, or state ID number) and financial account information (e.g., bank account details for payment purposes).

We collect SPI solely for the purposes of identity verification, AML compliance, and transaction processing as required by applicable law. We do not use SPI for purposes beyond those for which it was collected, and we do not sell or share SPI. You have the right to limit our use and disclosure of your SPI to these necessary purposes. To exercise this right, please contact us at [email protected] with the subject line "Limit Use of Sensitive Personal Information."

12. Cookies and Tracking Technologies — Detailed Disclosure

Our Site uses the following categories of cookies and tracking technologies:

Strictly Necessary Cookies: These cookies are essential for the Site to function and cannot be disabled. They are typically set in response to actions you take, such as setting your privacy preferences or filling in forms.

Analytics and Performance Cookies: We use analytics tools (including Google Analytics) to collect aggregated, anonymized information about how visitors use our Site, such as pages visited, time on site, and traffic sources. This data helps us improve the Site's performance and content. Google Analytics may set cookies on your device and may transfer data to Google's servers in the United States. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on available at tools.google.com/dlpage/gaoptout.

Functional Cookies: These cookies enable enhanced functionality, such as remembering your preferences. Disabling them may affect certain features of the Site.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our Site. For more information about cookies, visit www.allaboutcookies.org.

13. Your Right to Opt Out of Sale or Sharing

Palak Diam does not sell your personal information to third parties for monetary consideration, nor do we share your personal information for cross-context behavioral advertising purposes as defined under the CPRA.

If our data practices change in the future such that we engage in the sale or sharing of personal information, we will update this Privacy Policy and provide a "Do Not Sell or Share My Personal Information" link on our Site's homepage and footer as required by California law. At that time, California residents will have the right to opt out of such sale or sharing by clicking that link or contacting us directly.

For any questions about our current data sharing practices, please contact us at [email protected].

14. Data Breach Notification

In the event of a data breach that compromises the security, confidentiality, or integrity of your unencrypted personal information, Palak Diam will notify affected individuals in accordance with California Civil Code § 1798.82 and other applicable state and federal breach notification laws.

Notification will be provided in the most expedient time possible and without unreasonable delay, consistent with the legitimate needs of law enforcement and any measures necessary to determine the scope of the breach and restore the integrity of the data system. Notification may be provided by email, written notice, or, if the cost of notification would exceed $250,000 or the number of affected persons exceeds 500,000, by conspicuous posting on our Site.

If you believe your personal information held by Palak Diam has been compromised, please contact us immediately at [email protected] or (213) 228-0077.

15. Third-Party Analytics and Service Providers

We use the following categories of third-party service providers who may process your personal information on our behalf:

Analytics: Google Analytics (Google LLC) — website usage analytics. Google's privacy policy is available at policies.google.com/privacy.

Shipping and Logistics: FedEx Corporation — for arranging insured shipping of diamonds and jewelry. FedEx's privacy policy is available at fedex.com/en-us/privacy-policy.html.

Payment Processing: We may use third-party payment processors to facilitate wire transfers and other payment methods. These processors are subject to their own privacy policies and security standards.

Email Communications: We may use email service providers to send transactional and marketing communications. All such providers are contractually bound to use your information only as directed by us.

All third-party service providers are required to maintain the confidentiality and security of your personal information and are prohibited from using it for any purpose other than providing services to us.

16. Contact Our Privacy Team

Palak Diam has designated a Privacy Contact responsible for overseeing compliance with this Privacy Policy and applicable privacy laws. For all privacy-related inquiries, requests, or complaints, please contact:

Privacy Contact Palak Diam Inc. 550 S. Hill Street, Suite 1040 Los Angeles, California 90013

Email: [email protected] (Subject: "Privacy Request") Phone: (213) 228-0077

We will acknowledge receipt of your request within ten (10) business days and respond substantively within forty-five (45) days as required by California law. If we require additional time, we will notify you of the extension and the reason for it. There is no charge for submitting a privacy request. We will not discriminate against you for exercising your privacy rights.